Respondent operates a breakfast food production facility that uses ammonia as its refrigerant and has on-site for use, 15,000 pounds of ammonia. Respondent has one RMProgram level 3 covered process, an ammonia refrigeration process. On May 20, 2014, the EPA conducted an onsite inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes.
- The Respondent was not able to provide any written process safety information related to the ammonia sensors used in the engine room.
- The Respondent could not document that the following equipment complied with RAGAGEP.
- Doors entering the ammonia engine room did not have visual or audible alarms to alert of an ammonia release. The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 15, Section 8.11.2.1, indicates,
“The [ammonia] alarm shall annunciate visual and audible alarms inside the refrigerating machinery room and outside each entrance to the refrigerating machinery room. The meaning of each alarm shall be clearly marked by signage near the annunciators.”
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- Some of the ammonia piping did not have labels indicating the pipe contents or direction of flow. The International Institute of Ammonia Refrigeration (IIAR) Bulletin 109: IIAR Minimum Safety Criteria for a Safe Ammonia Refrigeration System, Section 4. 7 .6, indicates,
“All ammonia piping should have appropriate pipe markers attached to indicate the use of the pipe and arrows to indicate the direction of flow, such as in IIAR Bulletin 114.”
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- Bulletin 114: Guidelines for Identification of Ammonia Refrigeration Piping and System Components, Section 4.1 Piping Markers, indicates,
“Piping markers shall be designed to identify the refrigerant, the physical state of the refrigerant, and the relative pressure level of the refrigerant and the direction of flow.”
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- Some of the piping supports in the engine room were rusted. IIAR Bulletin 110, Section 6.7.1 indicates,
“All uninsulated piping and associated components such as flanges and supports shall be inspected annually for any damage to or deterioration of the piping or its protective finish; and remedial action taken where necessary. Areas affected by slight corrosion should be cleaned off and appropriately treated before reinstating the protective finish.”
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- A section of ammonia piping in the engine room had a section of insulation removed. A plastic bag was hung from the bottom of the pipe as to catch any liquids. IIAR Bulletin 110 Section 6.7.2, Insulated Piping indicates
“Any mechanical damage to insulation should be repaired immediately and the vapor seal reinstated to prevent access to water or water vapor which will lead to breakdown of insulation and corrosion of the pipework.”
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- The king valve on the high pressure receiver was not labeled. IIAR Bulletin 109, Section 4.10.3 indicates,
“The main shut off valve(s) (king valve(s)) should be identified with a prominent sign having letters sufficiently large to be easily read.”
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- The low-temperature recirculator located on the roof of the facility was not labeled. IIAR Bulletin 114, Section 4.2 indicates, “Component
“Component markers will bear the name of the equipment they identify. In additional, component markers will be provided with a pressure level designation.”
- The Respondent conducted a Process Hazard Analysis (PHA) in June December 2013. Recommendations for the PHA were listed, but there was no associated person assigned to any of the items, nor a date indicating when the items should be completed or if they had been completed.
- At the time of the inspection, the Respondent could not provide written procedures to maintain the on-going integrity of the process equipment.
- The Respondent could provide no information related to any test/inspection performed on process equipment by a contractor or employees (other than a daily log of a walkthrough of the engine room). HAR Bulletin 109 and 110 recommend inspections and tests that should be completed for ammonia refrigeration systems
- Two deliveries of anhydrous ammonia totaling 15,000 pounds were delivered to the facility in December 2013. The Risk Management Plan was submitted to the EPA on February 1, 2014. The threshold for ammonia for the Risk Management Program is 10,000 pounds.
TERMS OF CONSENT AGREEMENT
Respondent agrees to pay the civil penalty of FORTY THOUSAND TWO HUNDRED FIFTY DOLLARS ($40,250).
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